- 6 -
performing covered services. Sec. 1.448-1T(e)(4)(i), Temporary
Income Tax Regs., supra. In calculating the amount of employee
time spent performing covered services, administrative and
support services incident to covered services are treated as
covered services. Id.
Section 448(d)(2), the regulations thereunder, and court
opinions generally do not define accounting services.2 However,
in section 1.448-1T(e)(5)(vii), Example 1(i), Temporary Income
Tax Regs., 52 Fed. Reg. 22770 (June 16, 1987), the preparation of
tax returns and audit and financial statements are treated as
accounting services:
X, a corporation, is engaged in the business
of providing accounting services to its
clients. These services consist of the
preparation of audit and financial statements
and the preparation of tax returns. For
purposes of section 448, such services
consist of the performance of services in the
field of accounting. * * *
Petitioner concedes that, if tax return preparation and
bookkeeping services constitute accounting services, by virtue of
Rodgers’ and Rodgers’ estate’s ownership of petitioner’s stock,
the above ownership test has been satisfied.
2 In Ron Lykins, Inc. v. Commissioner, T.C. Memo. 2006-35,
the parties did not dispute that tax return preparation services
constituted accounting services.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011